The Supreme Court: Determining Who Is Disabled Under the ADA
Determining Who Is Disabled Under the ADA
Ever since the ADA was passed, the Supreme Court rulings have limited aspects of that law and the impact it has on both states and businesses. One such case is Toyota Motor Mfg. v. Williams decided on January 8, 2002.
“This court seems determined to set a very strict test for deciding who is disabled. You are either not disabled enough to be covered by the ADA or you are too disabled to do the job. That is not what Congress intended. A worker in Williams' position is now faced with a Catch-22. At the same time they are trying to show how much the impairment affects their daily life, they are also trying to prove they are qualified for the job. By proving you're disabled, you can prove yourself out of a job.”
—From the friend of the court brief submitted by the National Council on Disability
Ella Williams developed carpal tunnel syndrome in her upper extremities. This condition involves painful muscle and tendon injuries that resulted from highly repetitive motions, such as would be required on a Toyota assembly line. Toyota reassigned Williams to other positions, which worked for three years, but then Toyota added some task that reawakened the pain of carpal tunnel syndrome. Williams and Toyota disagreed about what happened next, but ultimately Williams was fired.
The district court ruled that Williams was not disabled because carpal tunnel syndrome had not substantially limited any major life activity and said there was not evidence that Williams had a record of “substantially limiting impairment.” The 6th Circuit Court reversed that decision because it found that Williams had demonstrated that her manual disability involved a class of manual activities that did affect her ability to perform tasks at work so some accommodation should have been made. The Supreme Court unanimously reversed the circuit court, finding that an impairment must be permanent or long-term.
In writing the opinion of the Court, Justice O'Connor ruled:
- “Given the large potential differences in the severity and duration of carpal tunnel syndrome, an individual's carpal tunnel syndrome diagnosis, on its own, does not indicate whether the individual has a disability within the meaning of the ADA.”
Keeping things equal can be a difficult balance that frequently pits the Congress against the Court. Next we'll explore the issues of freedom guaranteed by the First Amendment.
Excerpted from The Complete Idiot's Guide to The Supreme Court © 2004 by Lita Epstein, J.D.. All rights reserved including the right of reproduction in whole or in part in any form. Used by arrangement with Alpha Books, a member of Penguin Group (USA) Inc.